ITO v. Bhagchand Jain (2022) 94 ITR 472 / 217 TTJ 202 (Jaipur)(Trib.)

S. 145 : Method of accounting-Estimation of income in an arbitrary, capricious, and wild manner is not permitted in the eyes of the law and must be on a reasonable basis in congruent to the result of the prior previous years. [S. 145(3)]

Held that the AO is bound to make an honest estimation of income keeping in view the material available on record, past history of the case, local knowledge, and repute of the assessee. At the same time, the A.O. is also supposed to collect necessary material for the purpose, if so required. The assessee placed on record iron sector report of financial year 2013-14 which showed the ratio and reason of decline in iron market to explain the market conditions. Thus, taking into consideration the totality of the facts and circumstances of the case, addition was restricted to the GP rate of 2.04%. (AY.2014-15)